20 March 2013
COMMENTS ON DRAFT EIA REPORT FOR THE PROPOSED GOEREESOE WIND FARM, NEAR
SWELLENDAM
DEA Ref: 12/12/20/2199
Dear Mr Johnston,
Please find
below our comments on this DEIA. The first question to be answered is why was
the original Environmental Assessment Practitioner company, Doug Jeffrey, replaced
by Savannah Environmental?
AVIFAUNA
The Avifauna Scoping Reports were prepared by Chris
van Rooyen, a recognized specialist in this field who has been involved with
this project from the outset, and who has extensive experience with
environmental avifaunal assessments in South Africa, including much work in the
Overberg. Why has he now been replaced during the Environmental Assessment
phase by Bio 3, a Portuguese company with little if any local experience of
Southern African birdlife?
- In the DEIA report they state they are using previous scoping data supplemented by a 3 day visit in late November 2012. However impressive their stated methodology might appear, the results of this assessment are lacking in confidence and insufficient for EIA purpose.
- Their limited knowledge of SA avifauna is evidenced by their inclusion of priority species in Table 7 of such unlikely species at this site of Damara Tern and Palmnut Vulture. There is further evidence of this in Table 9 showing many species (27) that they could not identify at all, or at best at genus level (10). What confidence does this inspire?
- This is further compounded by Table 10.3, Appendix IV which lists all species previously recorded in this QDS, but with no attempt made to highlight what species might actually be likely to occur at this inland site. Thus giving rise to an absurd list which includes Albatrosses, Petrels, Gannets and Penguins, and this more than 30 Km from the nearest seashore or ocean!
- Their data sources do not include reference to, or data from, the Coordinated Avifaunal Road Count programme at the Animal Demography Unit in Cape Town.
- Species of conservation concern which are notably absent or found in small numbers in the transect report (Blue Crane 1 bird!) include, Blue Crane (100%), Denham’s Bustard (40%), Black Harrier (20%), as well as common Overberg species such as Jackal Buzzard (80%). Figures in brackets are the SABAP2 reporting rates.
- Table 10 purports to report on raptors and large terrestrial species observed in November 2012, yet the column is headed ‘July.’
- No nesting sites were found during the November visit. The peak breeding period of the Blue Crane in the Overberg of mid-December through January has not been assessed. Which is no doubt the reason why no Blue Crane nests were found.
- It is surprising that Blue Cranes were not observed near the numerous water bodies on site. Though perhaps not surprising considering the very short, only a matter of minutes, visits to water bodies. Had they had local knowledge or consulted local sources they would have looked more carefully and been alerted to this unexpected finding.
- The validity of the statement regarding the Control area that “species richness was similar in both areas” is thrown into doubt by the fact that the two main species of concern, namely Blue Crane and Black Harrier, were not observed in the Control area. Again, local knowledge would have alerted them to this discrepancy.
- Several turbines appear to be placed in, or dangerously close, to the 150m riparian buffer zones. It is established fact that Blue Cranes roost in water bodies, and prefer nesting nearby. Dams and wetlands therefore constitute habitats of high risk potential for causing collisions with power lines, not only for Blue Cranes which often arrive at times of poor visibility, but for other species such as White Storks.
- The proposed year of “pre-construction” baseline monitoring covering all 4 seasons, as recommended in the SA Best practice guidelines, has not been completed, with only one very short visit in summer.
This report is grossly insufficient for environmental authorization
purposes.
BATS
Of particular concern is that there is no mention of the
site falling within 35 km of an important, and one of the largest bat roosts in
southern Africa, the De Hoop Guano Cave.
There has not been a full year of bat baseline
monitoring, covering all 4 seasons, in
accordance with the South African Good Practice Guidelines for Surveying Bats
in Wind Farm Developments, 2012, with only one short site visit in October
2012. There are therefore no seasonal
data on which to base any reasonable assessment, and therefore by which to
guide turbine placement.
There are insufficient data on which to make an
assessment for authorization.
VEGETATION
- Although much of the land has been transformed, there is still sufficient remaining renosterveld to warrant close investigation during all seasons of the year, and its subsequent protection. Natural vegetation must include that which has been partly invaded by alien vegetation, as in many instances it is capable of recovery. All turbines and elements of infrastructure should be placed so as to avoid Renosterveld, whether partly transformed or pristine, and additionally so as to avoid interrupting ecological corridors.
- It is essential that the recommendations of the specialist botanist should be accepted and incorporated into the design layout of the turbines and all infrastructure. It would appear that this advice is still being ignored which will result in the irretrievable loss of Critically Endangered Renosterveld categories.
CUMULATIVE IMPACTS
All the potential local and regional cumulative
impacts of this and the three proposed neighbouring wind farms, two of which
have received DEA authorization, must be addressed comprehensively.
This is particularly so for impacts with low
certainty, but with potential for serious impacts.
It is
imperative that the DEA and DEA&DP consider cumulative impacts of this and
other WEFs in the vicinity.
We fully support
the comments from CapeNature dated 2 April 2012.
In conclusion, it should be imperative that results of
both the avifauna and bat monitoring programmes should be made available to all
registered I&APs and sufficient time allowed for further comments before
completion of the Final EIA Report. The final plans, layouts and micro-siting
of all components of the wind farm should be informed by the necessary data. It
is inconceivable that Authorisation can be even contemplated by the Competent
Authority before all data are available.
We expect that all comments in this letter will be
taken into account during the remainder of the EIA phase, and will be
circulated to other I&APs. We reserve the right to revise these comments
and to make more comments if considered necessary.
Cc.
By email to:
BirdLife South Africa; Endangered
Wildlife Trust; CapeNature; BirdLife Overberg; Overberg Lowlands Conservation
Trust; Overberg Crane Group; CAR Project, Animal Demography Unit
REFERENCES
- Modelling power-line collision risk for the Blue Crane Anthropoides paradiseus in South Africa
Jessica M. Shaw,
Andrew R. Jenkins, Jon J. Smallie, Peter G. Ryan: Ibis (2010), 152, 590–599
- Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites in southern Africa, 2012.
- South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments, Draft 3, 2012.
- Avian Wind Farm Bird Sensitivity Map.
- DEADP Guideline on Biodiversity Offsets. October 2011
- Coordinated Avifaunal Roadcounts (CAR) Project; Animal Demography Unit , Dept. of Biological Sciences, UCT
- Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape. Towards a regional methodology for wind energy site selection. Report 6: Proposed Project Level Methodology. DEADP
- Breeding habitat selection and reproductive success of Blue Cranes Anthropoides paradiseus in an agricultural landscape of the Western Cape, South Africa. Mark T Bidwell. Unpublished MSc thesis (Conservation Biology), Department of Zoology, UCT. March 2004.
- AC Doty & AP Martin (2012): Assessment of bat and avian mortality at a pilot wind turbine at Coega, Port Elizabeth, Eastern Cape, South Africa, New Zealand Journal of Zoology,
DOI:10.1080/03014223.2012.741068
http://dx.doi.org/10.1080/03014223.2012.741068
